State v. Arias
140 A.3d 200
| Conn. | 2016Background
- Defendant Rafael Arias, manager of a dental office, was convicted by a jury of first‑degree and third‑degree sexual assault for forcibly kissing and groping employee M and inserting a finger into her vagina.
- M reported the incident to police the next day; Detective Hudyma met with Arias at the Norwalk police station after Arias voluntarily presented himself and gave oral and written statements admitting the contact but claiming consent.
- Arias moved to suppress his statements, arguing he was not Mirandized because he was effectively in custody during questioning at the station.
- The state sought to admit testimony from other female employees that Arias had touched them inappropriately; the trial court admitted that evidence as relevant to intent, motive, absence of mistake, and initially indicated admissibility under State v. DeJesus for propensity, then limited the jury charge to intent/motive/absence of mistake. Arias did not object at trial to the final charge.
- Arias appealed, arguing (1) the suppression ruling was erroneous, (2) admission of prior sexual misconduct under DeJesus was improper, and (3) DeJesus/Conn. Code Evid. §4‑5(b) violates equal protection.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Arias was in custody such that his statements required Miranda warnings | State: Arias voluntarily came to the station, was free to leave, not restrained, and thus not in custody | Arias: Police questioning in an interview room, armed officers in vicinity, and seizure of his phone made him feel not free to leave — custodial interrogation | Court: Not in custody; objective factors (initiation, no restraints, one hour, left unaccompanied) show no Miranda requirement; suppression denial affirmed |
| Admissibility of uncharged sexual misconduct under DeJesus/Conn. Code Evid. §4‑5(b) | State: Evidence relevant to intent, motive, absence of mistake and (initially) propensity under DeJesus; similar victims and timing | Arias: Evidence overly prejudicial, remote, dissimilar; DeJesus limited to grotesque/abhorrent conduct so inapplicable here | Court: Evidence admissible at least to show intent, motive, and absence of mistake; defendant conceded those bases and did not preserve a pure DeJesus challenge, so no reversible error |
| Equal protection challenge to rule permitting propensity evidence in sexual‑offense cases | Arias: §4‑5(b) treats sex‑offense defendants differently, undermining presumption of innocence and right to fair trial | State: Rule is rationally related to legitimate interest in effective prosecution; prior federal and state cases reject equal protection challenge | Court: No fundamental right or suspect class implicated; applied rational‑basis reasoning and rejected equal protection claim |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (Miranda warnings required for custodial interrogation)
- State v. DeJesus, 288 Conn. 418 (Conn. 2008) (permitting propensity evidence in certain sexual‑misconduct cases)
- State v. Mangual, 311 Conn. 182 (Conn. 2014) (factors for determining custody for Miranda purposes)
- United States v. Enjady, 134 F.3d 1427 (10th Cir. 1998) (rejecting equal protection challenge to federal rule permitting propensity evidence in sexual assault cases)
- United States v. LeMay, 260 F.3d 1018 (9th Cir. 2001) (same; propensity evidence does not implicate a fundamental right to a trial free from relevant propensity evidence)